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involve questions of fact as these would require the examination and determination of
the evidentiary weight of the documents submitted by the latter, specifically the
medical certificate issued by Dr. Vicaldo and the Deed of Release, Waiver and Quitclaim
executed by him. They posit that factual issues may not be passed upon by this Court
through a petition for review on certiorari under Rule 45 and Andrada did not cite any
circumstances that could warrant exemption from this rule.
On the merits, the respondents argue that Andrada's entitlement for disability benefits
was negated by the pronouncement of his fitness to work by Dr. Ramos, the companydesignated physician, and by Dr. Faylona, the physician who treated him extensively.
They stress that the CA was correct in not giving weight on the medical assessment of
Andrada's private doctor, Dr. Vicaldo, because the same was not supported by any
medical record and was issued after a single medical check-up done merely ten days
after his surgery. They assert that Andrada's alleged disability is not compensable
because his umbilical hernia was pre-existing. Lastly, they contend that the Deed of
Release, Waiver and Quitclaim is valid, and cover all possible claims that Andrada may
have against them including the disability benefits.
The Court’s Ruling
From a perusal of the arguments of Andrada, it is quite apparent that this petition is
raising questions of facts inasmuch as this Court is being asked to revisit and assess
anew the factual findings of the CA and the NLRC. Andrada is fundamentally assailing
the findings of the CA and the NLRC that the evidence on record did not support his
claim for disability benefits. In effect, he would have the Court sift through, calibrate
and re-examine the credibility and probative value of the evidence on record so as to
ultimately decide whether or not there is sufficient basis to hold Agemar Manning and
Sonnet Shipping accountable for refusing to pay for his disability benefits under the
POEA's Revised Standard Terms and Conditions Governing the Employment of Filipino
Seafarers on Board Ocean-Going Vessels, which is deemed written in his contract of
employment. This clearly involves a factual inquiry, the determination of which is the
statutory function of the NLRC.[14]
Elementary is the principle that this Court is not a trier of facts and this doctrine applies
with greater force in labor cases. Questions of fact are for the labor tribunals to resolve.
[15]
Only errors of law are generally reviewed in petitions for review on certiorari
criticizing decisions of the CA. Moreover, findings of fact of quasi-judicial bodies like the
NLRC, as affirmed by the CA, are generally conclusive on this Court.[16]
In exceptional cases, however, the Court may be urged to probe and resolve factual
issues when there is insufficient or insubstantial evidence to support the findings of the
tribunal or the court below, or when too much is concluded, inferred or deduced from
the bare or incomplete facts submitted by the parties or, where the LA and the NLRC
came up with conflicting positions.[17] In the case at bench, considering the conflicting
findings of the LA, on one hand, and the NLRC and the CA, on the other, this Court is
impelled to resolve the factual issues along with the legal ones. The core issue is
whether or not Andrada is entitled to disability benefits on account of his medical
condition.
elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/55246
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